The suit's central claim: Ronquillo, an alleged car thief, was merely trying to get away from an unprovoked assault by Denver officers when he backed his car into another cop. As a result, police prompted Ronquillo's self-defensive actions, then failed to give him an adequate chance to surrender before killing him.

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The latest developments? The City and County of Denver, the target of complaints involving Denver officers and one Jefferson County defendant, Luke Ingersoll, has filed a motion to dismiss the matter, which was deemed justified after an investigation by the Denver District Attorney's Office.

Attorney John Holland, who represents Sanchez in concert with other members of his law firm, Holland Holland Edwards Grossman, has reacted to the dismissal call with motions of his own. The documents, on view below, raise questions about "video distortions" in a clip submitted by the defense and characterizes the officers who swarmed around Ronquillo at the funeral home as "frenzying piranhas."

April Sanchez, Ryan Ronquillo's mother.

Photo by Michael Roberts

"The police assaulted him in a collective group action," Holland says. "This conduct was deliberate and purposeful and created a natural human response by Ryan Ronquillo, who accurately perceived that his life was in danger."

As we've reported, the lawsuit's "statement of facts" notes that Ronquillo was killed outside the Romero Funeral Home, located at 4750 Tejon Street, at around 6 p.m. on July 2, 2014 — but he'd been at the facility prior to that time. Witnesses say they saw him as early as 4:15 p.m., more than an hour after members of the Safe Streets Fugitive Task Force first put him under surveillance; he was wanted on car-theft warrants. Police reports say he was being tracked by GPS coordinates as early as 2:45 p.m.

Far from being surprised that Ronquillo showed up at a funeral home, numerous officers told investigators they knew about the location in advance — defendants Ernest Sandoval, Brian Marshall, Jeffrey DiManna and Daniel White among them, the suit states. On top of that, multiple police calls from Detective Adam Lucero, part of the Denver gang unit, made mention of the funeral. And in a post-shooting interview, Sandoval said he "learned over the radio that Ronquillo had backed his vehicle into a parking spot at a funeral home and they were going to attempt to arrest him there.”

A surveillance camera captured images of Ronquillo parking and what happened afterward. Unfortunately, the altercation inside the passenger compartment of the vehicle Ronquillo was driving is partly obscured in the clip by two police SUVs, which zoom toward him in an effort to prevent his escape.

...and then converging on the passenger compartment, with one appearing to have drawn a weapon:

Holland Holland Edwards Grossman

The video indicates that the officers made their move before Ronquillo could get out of his vehicle or even turn it off — decisions that the lawsuit says contradict "proper procedures for a high-risk felony stop." And that's not to mention the speed with which the SUVs were traveling, particularly in light of the number of funeral attendees in the vicinity. A witness said the police vehicles "almost hit two little girls" — and one of the defendants, Officer Tina Trujillo, stated that she was almost struck by them, too, the lawsuit says.

Trujillo parked directly behind Ronquillo's vehicle, and after she exited her ride, she approached from the rear — a tactic the lawsuit deems reckless. She also admitted during post-incident testimony that she never heard any of the other officers issue Ronquillo a command to give himself up, and numerous other witnesses said likewise. But Holland doesn't see this question as key, given the suddenness of the attack against Ronquillo that followed.

"If I yell at you to stop the car while punching you in the face, you don't really have an opportunity to surrender," he told us back in June.

In his sworn statement, Sandoval admitted to doing the pounding. He said he "ran up to the driver's side of Mr. Ronquillo's vehicle," "ripped the suspect's shirt-collar area," pulled a lanyard from around the neck and "punched [Mr. Ronquillo] several times in the head."

Sandoval stressed that his punches had no effect on Ronquillo: "It didn't work it all," he said. The lawsuit rejects this claim based on a postmortem photo that showed a laceration to the suspect's mouth.

Holland Holland Edwards Grossman

In the meantime, Ingersoll, the Jeffco defendant, broke out the passenger-side window of Ronquillo's car and grabbed him by the hand or arm as he drove backward. The tools used on the windows included batons, flashlights, gun butts and clubs, the lawsuit says.

In light of the attack, the lawsuit brands Ronquillo's contact with Trujillo as "accidental."(He also struck two vehicles while backing up, one of them a police car.)

Another excerpt reads: "At the time he was shot and killed, Mr. Ronquillo did not pose an actual and imminent threat to the lives of any officers or civilians present at the scene. In backing up, Mr. Ronquillo was not targeting the car at any officer, but rather was positioning his vehicle in the natural direction of the road to escape the continuing assault.

"These officers also had no reason to believe that just letting Mr. Ronquillo drive away would pose a threat of serious physical harm to the officers or others, if it was even possible given the position of surrounding cars and the wedge," the lawsuit continues. "Mr. Ronquillo never displayed any violence, nor did he display any tendency to drive dangerously throughout the day. In fact, by their own accounts, officers were peacefully following him for hours."

Attorney John Holland.

Photo by Michael Roberts

Denver rejects the scenario laid out by the plaintiffs — something Holland calls "predictable." But, he adds, "motions to dismiss are disfavored by the courts, especially in excessive-force cases, where decisions are so heavily factually laden."

In his view, "the law is clear, and it has been clear since 1993 in this circuit and since 1985 under Supreme Court precedent — that the circumstances of a seizure are relevant and critical in assessing the reasonableness or objectivity of the use of deadly force. Case after case after case has held that police may not create the circumstances of a crisis like this and then evade responsibility because they later allegedly became afraid." Previous rulings cited in the responses include Sevier v. City of Lawrence, Kansas, Pauly v. White and Medina v. Cram.

One of the response documents puts it this way: "If the police had stuck to their plan to 'land' him out of his car, he was easily arrested by these officers after he got out of his car. But, rather than employ constitutional tactics, Defendants did exactly what they are trained, instructed and encouraged to do. They did not wait for him or give him even the slightest opportunity to surrender. They acted like a school of frenzying piranhas, attacking Ryan Ronquillo putting him in fear of imminent death or severe bodily injury."

And then there's the section of the response labeled "Video Distortions."

Another Facebook photo of Ryan Ronquillo.

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Holland says surveillance video submitted by Denver "shows Ryan Ronquillo pulling into the parking lot, and it looks like there's three seconds before the two officers pull up and wedge him in. But it's actually thirty seconds; you can tell because their version has time stamps. So they elided the video. I don't know if the video is gone or the camera was at a different angle. But that's missing. There's a thirty-second gap."

Now that the responses to the dismissal motion have been filed, the presiding judge will either hold a hearing to determine if the case should move forward or simply issue a decision — and Holland believes precedent is on his side.

"The court has to assume the facts as they were pleaded and apply clearly established law," he says. "And the law says you can't establish a crisis — and that's what happened here."

Continue to see the two responses and an exhibit featuring information about Ronquillo's autopsy.

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Michael Roberts has written for Westword since October 1990, serving stints as music editor and media columnist. He currently covers everything from breaking news and politics to sports and stories that defy categorization.